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Privacy policy

 

PRIVACY POLICY

HORSE-TRADE.PL

valid from 25.05.2018

 

§1

DEFINITIONS

 

  1. Administrator of Personal Data (ADO) – Start Riding sp. z o.o. who owns the Internet Store available under the domain www.horse-trade.pl.
  2. Personal data – all information on a natural person identified or identifiable by one or more specific factors defining physical, physiological, genetic, psychological, economic, cultural or social identity, including IP of the device, location data, Internet identifier and information collected through cookies and other similar technology.
  3. Policy – This Privacy Policy.
  4. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 of April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
  5. Act – Act of 10 May 2018 on the protection of personal data 2018 pos. 1000).
  6. Online shop –an online store (hereinafter a shop) run by the Administrator at www.horse-trade.pl
  7. User – any natural person visiting the store and using one or more services or functionalities described in the Politics.

 

§2

DATA PROCESSING IN CONNECTION WITH SAMPLE USE

 

  1. In connection with the user's use of the store, the Administrator collects the data to the extent necessary to provide the individual services and goods offered, as well as information about the user's activity in the store. Below are detailed rules and purposes for the processing of personal data collected during the use of the store by the User.

 

§3

OBJECTIVES AND LEGAL GROUNDS FOR THE PROCESSING OF DATA IN SAMPLE

 

  1. The personal data of all persons using the store (including IP address or other identifiers and information collected through cookies or other similar technologies) shall be processed by the Administrator:
    1. for the provision of services by electronic means, for the handling of orders, for the sale of goods and services in the scope available to the Users of store content, information about goods services, for the provision of contact forms – then the legal basis for processing is the necessity of processing for the performance of the contract (Article. 6 paragraph. 1 lit. b GDPR);
    2. in order to handle orders- then the legal basis for processing is the necessity of processing for performance of the contract (Article. 6 paragraph. 1 lit. b GDPR);
    3. in order to handle complaints - then the legal basis for processing is the necessity of processing to perform the contract and handling any claims (art. 6 paragraph. 1 lit b GDPR);
    4. for analytical and statistical purposes – then the legal basis for processing is the legitimate interest of the Administrator (art. 6 paragraph. 1 lit f GDPR) consists of conducting analyses of the activity of Users, as well as their preferences in order to improve the functionality and services provided;
    5. for the possible establishment and enforcement of claims or defence against them, the legal basis for the processing is the legitimate interest of the Administrator (art. 6 paragraph. 1 lit f GDPR) to protect its rights;
    6. for marketing purposes of the Administrator – the legal basis for processing is the legitimate interest of the Administrator (art. 6 paragraph. 1 lit f GDPR) consists of providing the ordered marketing communication, including in the form of newsletters, i.e. e-mail messages containing information about current offers, promotions or competitions.
  2. The User's activity in the store, including his personal data, is recorded in system logs (a special computer program used to store chronological records containing information about events and activities concerning the IT system used to provide services by the Administrator). Information collected in logs processed in connection with the provision of services. The controller shall also process it for technical purposes in particular, the data may be temporarily stored and processed in order to ensure the security and proper functioning of the IT systems, e.g. in connection with the making of security copies, the testing of changes to information systems, the detection of irregularities or the protection against fraud and attacks.

 

§4

ANNEX I

 

  1. The administrator shall ensure that it is possible to contact him via e-mail by writing to the e-mail address using the contact form. The use of e-mail requires the provision of personal data necessary to contact the User and answer the request. The user may also provide other data to facilitate contact or handling of the query. The provision of mandatory data is required to accept and handle the query, and failure to do so results in inability to operate. It is voluntary to provide other data.
  2. Personal data shall be processed:
    1. in order to identify the consignor and to handle his request sent by the form, the legal basis for the processing is the necessity of processing for the performance of the service contract (Article. 6 paragraph. 1 lit. b GDPR);
    2. for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (art. 6 paragraph. 1 lit. f GDPR) consisting of conducting statistics of queries submitted by Users via the Online Store to improve its functionality.

 

§5

MARKING

 

  1. The Administrator shall process the User's personal data in order to carry out marketing activities that may consist of:
    1. directing e-mail notifications of interesting offers or content which in some cases contain commercial information;
    2. other activities related to the marketing of direct services and goods (electronic transmission of commercial information and telemarketing activities).
  2. In some cases, the Administrator may use profiling to carry out marketing activities. This means that thanks to automated data processing, the Administrator evaluates selected factors concerning individuals in order to analyse their behaviour or create forecasts for the future.
  3. The Administrator processes personal data of Users for marketing purposes in connection with directing to Users advertising and commercial information of a contextual nature (i.e. advertising and commercial information that is not tailored to your preferences). The processing of personal data then takes place in connection with the fulfilment of the legitimate interests of the Administrator (art. 6 paragraph. 1 lit. f GDPR).
  4. The Administrator does not process the personal data of Users, including in particular personal data collected through cookies and other similar technologies, for marketing purposes to direct behavioral advertising to Users (i.e. advertising that is tailored to your preferences).
  5. The user should remember that consent to the use of cookies can be expressed through the appropriate configuration of the browser and can be withdrawn at any time, in particular by clearing the history of cookies and shutting down the use of cookies in the settings of the browser.
  6. If you have agreed to receive marketing information via e-mail of other means of electronic communication, your personal data will be processed for the purpose of sending such information. The basis for data processing is the legitimate interest of Start Riding sp. z o.o. in sending marketing information within the limits of the consent granted by the User. You have the right to object to the processing of data for direct marketing purposes, including profiling. The data will be stored for this purpose for the duration of the legitimate interest of Start Riding sp. z o.o., unless you object to receiving marketing information.
  7. Consent to carry out marketing activities may be withdrawn at any time.

 

§6

SOCIAL PORTS

 

  1. The Administrator processes personal data of Users visiting the Administrator's profiles conducted on social media (e.g. Facebook). This data is processed exclusively in connection with the profile, including to inform Users about the activity of the Administrator and to promote various types of events, services and goods, as well as to communicate with users through the functionality available on social media.
  2. The legal basis for the processing of personal data by the Administrator for the purpose indicated above is its legitimate interest (Article. 6 paragraph. 1 lit. f GDPR) consisting of promoting its own brand and building and maintaining a community associated with the brand.

 

§7

COOKIES FLICKS AND LIKE TECHNOLOGY

 

  1. Cookies are small text files installed on the User's device browsing the store. Cookies collect information that facilitates the use of the website – e.g. by remembering your visits to the store and the activities it performs.
  2. The Administrator uses so-called service cookies primarily to provide the User with services provided by electronic means and to improve the quality of these services. Therefore, the Administrator and other entities providing analytical and statistical services for him use cookies, storing information or gaining access to information already stored in the User's telecommunications terminal device (computer, phone, tablet, etc.). Cookies used for this purpose include:
    1. cookies with data entered by the User (session identifier) for the duration of the session;
    2. authentication cookies used for authentication services for the duration of the session;
    3. security cookies, e.g. used to detect fraud in authentication;
    4. session media player cookies (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
    5. permanent cookies to personalize the User interface customization cookies,
    6. cookies used to remember the contents of the basket for the duration of the session;
    7. cookies to monitor traffic on the website, i.e. data analytics, including Google Analytics cookies (these are files used by Google to analyze how the store is used by the User, to produce statistics and reports on the functioning of the store). Google does not use the collected data to identify you or combine this information to allow identification. Detailed information about the scope and rules of data collection for this service can be found at: https://www.google.com/intl/pl/policies/privacy/partners.
  3. The Administrator also uses cookies for marketing purposes, including in connection with directing behavioral advertising to Users. For this purpose, the Administrator stores information or accesses information already stored in the User's telecommunications terminal device (computer, phone, tablet, etc.). The use of cookies and personal data collected through them for marketing purposes, in particular as regards the promotion of third party services and goods, requires the consent of the User. This consent can be expressed by the appropriate configuration of the browser, and can be withdrawn at any time, in particular by clearing the history of cookies and shutting down the use of cookies in the settings of the browser.

 

§8

PERSONAL DATA PROCESSING PERIOD

 

  1. The period of processing of data by the Administrator depends on the type of service provided and the purpose of the processing. In principle, the data are processed by the time the service is provided, pending the withdrawal of the consent expressed or the effective objection to the processing of data in cases where the legal basis for the processing of data is the legitimate interest of the Administrator.
  2. The period of processing of data may be extended where processing is necessary to establish and pursue any claims or defence against them, and thereafter only if and to the extent required by the law. At the end of the processing period, the data shall be irreparably deleted or anonymised.

 

§9

POWERS OF THE USER

 

  1. Persons whose data are processed by the Administrator shall have the following rights:
    1. The right to information about the processing of personal data – on this basis to the person submitting such a request, the Administrator shall provide information about the processing of personal data, including in particular about the purposes and legal bases of the processing, the scope of the data held, the entities to which the personal data are disclosed and the planned date of their deletion;
    2. Right to obtain a copy of the data – on this basis, the Administrator shall transmit a copy of the data processed concerning the person submitting the request;
    3. Right to rectify – on this basis, the Administrator removes any inconsistency or errors concerning the personal data processed, and supplements or updates it if it is incomplete or has changed;
    4. Right to delete data – on this basis, it may be requested to delete data which are no longer necessary for the processing of any of the purposes for which they have been collected;
    5. The right to restrict processing – on this basis, the Administrator ceases to carry out operations on personal data, except for operations authorised by the data subject and their storage, in accordance with accepted retention rules, or until the reason for the restriction of data processing ceases (e.g. decisions of the supervisory authority, allowing further processing of data);
    6. The right to transfer data – on this basis, to the extent that the data are processed in connection with the contract concluded or the consent expressed, the Administrator shall issue the data provided by the person concerned in a format allowing them to be read by the computer. It is also possible to request that this data be sent to another entity – however, provided that there are technical possibilities in this respect both on the Administrator's side and on that other entity;
    7. Right to object to the processing of data for marketing purposes — the data subject may at any time object to the processing of personal data for marketing purposes without the need to justify such an objection;
    8. The right to object to other purposes of data processing – the data subject may at any time object to the processing of personal data on the basis of a legitimate interest of the Administrator (e.g. for analytical or statistical purposes or for reasons related to the protection of property). The objection in this respect should include a justification and be subject to an assessment by the Administrator;
    9. Right to withdraw consent – if the data are processed on the basis of consent, the data subject has the right to withdraw it at any time, but this does not affect the legality of the processing carried out before the withdrawal of the consent;
    10. The right to a complaint – if it is recognised that the processing of personal data violates the provisions of the GDPR or other provisions concerning the protection of personal data, the data subject may lodge a complaint with the President of the Office for Personal Data Protection, ul. Rates 2, 0-193 Warsaw.
  2. A proposal for the implementation of the rights of data subjects may be submitted:
    1. in writing to: Start Riding sp. z o.o. ul. Michał Korpal 4, 30-389 Kraków
    2. by e-mail via contact form
  3. The proposal should, where possible, specify precisely what the request concerns, i.e. in particular:
    1. the right to obtain a copy of the data, the right to delete the data, etc.;
    2. which processing process is concerned with the request (e.g. use of a particular service, website activity, receipt of a newsletter containing commercial information to a specific email address, etc.);
    3. the processing purposes of the request (e.g. marketing objectives, analytical objectives, etc.).
  4. If the Administrator is unable to determine the content of the request or identify the applicant on the basis of the application made, it will request additional information from the applicant.
  5. A reply to the notification shall be given within one month of receipt of the notification. If it is necessary to extend this deadline, the administrator shall inform the applicant of the reasons for this extension.
  6. The reply will be sent to the e-mail address from which the request was sent and, in the case of requests sent by letter, to the address indicated by the applicant, unless the letter indicates a wish to receive feedback to the e-mail address (in which case the e-mail address must be provided).

 

§10

DATA RECIPIENTS

 

  1. In connection with the provision of services, personal data will be disclosed to external entities, including in particular to providers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing accounting, legal, audit, consulting, couriers, marketing agencies (in the field of marketing services).
  2. If the User consents, his data may also be made available to other entities for their own purposes, including marketing purposes.
  3. The Administrator reserves the right to disclose the selected information concerning you to the competent authorities or third parties who request such information on the basis of an appropriate legal basis and in accordance with the applicable law.

 

§11

TRANSMISSION OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

 

  1. The level of protection of personal data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator shall transmit personal data outside the EEA only where necessary and with an adequate degree of protection, in particular by:
    1. cooperation with data processors in the countries for which the relevant decision of the European Commission has been issued;
    2. the use of standard contractual clauses issued by the European Commission;
    3. the application of binding corporate rules, approved by the competent supervisory authority;
    4. If data is transmitted to the US, cooperation with entities participating in the Privacy Shield, approved by a European Commission decision.
  2. The administrator shall always inform of the intention to transfer personal data outside the EEA at the stage of their collection.

 

§12

SECURITY OF PERSONAL DATA

 

  1. The administrator shall conduct a risk analysis on an ongoing basis in order to ensure that personal data are processed safely by him – ensuring, first of all, that only authorised persons have access to the data and only to the extent that this is necessary due to their tasks. The administrator shall ensure that all operations on personal data are recorded and carried out only by authorised employees and co-workers.
  2. The administrator shall take all necessary steps to ensure that its subcontractors and other co-operating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of the Administrator.
  3. The administrator did not appoint a Data Protection Officer.

 

§13

CHANGE IN PRIVACY POLICY

 

  1. The policy shall apply from 25.05.2018, shall be reviewed and updated as necessary.